November 19 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave. S.E. Washington, D.C. 20590

RE: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations from Certain Provisions of 14

C.F.R.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14

C.F.R. Part 11, The University of Idaho College of Law, Small Business Legal Clinic files this

petition on behalf of Gulo GIS Consulting, LLC (“Gulo”), an operator of unmanned aircraft

systems (UAS) used for agricultural surveillance and research.

Specifically, Gulo seeks an exemption for the operation of two UAS platforms: (1)The

Universeye Finwing Penguin, and (2) The DJI Phantom 3 Professional. The following

exemption applications provides a detailed explanation of why Gulo is seek ing this exemption

and what steps Gulo will take to ensure the safe operation of both platforms while complying

with all applicable rules and laws. Please do not hesitate to contact either Jeremy Tamsen or

Cody Earl at the University of Idaho College of La w should you have any questions or concerns.

Respectfully,

Jeremy Tamsen

Cody Earl- 2 of 15

- Publishable Summary

Pursuant to 14 C.F.R. § 11, the following summary is provided for publication in the Federal Register, should it be deemed that publication is needed:

Petitioner seeks an exemption from the following Federal Aviation Regulations (FAR) :

21(h); 43.7; 43.11; 45.11; 45.27; 45.29; 61.113(a) and (b); 61.23; 91.7(a); 91.9(b)(2) and (c); 91.103(b)(2); 91.105; 91.109; 91.113(b); 91.119(c); 91.121; 91.151( a); 91.203 (a) and (b); 91.215; 91.403; 91.405(a); 91.407(a)(1); 91.409(a)(1) and (a)(2); 91.417(a) and (b).

Approval for the exemption for Petitioner will allow commercial operation of the Universeye Finwing Penguin and the DJI Phantom 3 Professional for the collection of aerial data, aerial inspection, aerial photography , and aerial videography. The requested exemption should be granted because the operation of these two unmanned aircraft systems (UAS) will strictly adhere

to the conditions outlined belo w, will provide an equivalent level of safety, and will benefit the public in a variety of ways. Furthermore, this exemption request comports perfectly to the seven factors Congress has directed the FAA to consider when approving Section 333 exemption peti tions: (1) size; (2) weight, (3) speed, (4) operational capability, (5) proximity to airports, (6) proximity to populated areas, and (7) operation within visual line of sight. Specifically, the UAS’s are small in size and will be operated at slow speeds cl ose to the ground. The substantial increase of safety and decrease of human life, coupled with low risk use of UAS’s to conduct these operations, weigh heavily in favor of granting the exemption.

I. Petitioner’s Contact Information

Gulo GIS Consulting, LLC Jeffrey J. Lonneker, General Manager

1022 E. 8 th Street Moscow, Idaho 83843 Phone: (208) 615

- 5452 Email: jeff@gulogisconsulting.com

Counsel for Petitioner The University of Idaho, College of Law Small Business Legal Clinic 514 W. Jefferson, Room 123 Boise, Idaho 83720

- 0051 Phone: (208) 364

- 4074- 3 of 15

- II. Proposed Operations

a. Platforms

The requested exemption will permit Petitioner to operate both: (i) the Universeye Penguin, and (ii) the DJI Phantom 3 Professional. Both of these platforms have been exempted fr om the certification procedures for products and parts in other exemption petitions (see exemption nos. 11318 and 13101), and therefore do not require a Certification of Airworthiness for operations. The UAS platforms will be operated in a manner that conf orms to guidelines, rules, and regulations applicable to a Section 333 exemption, including such restrictions and conditions

which are expressed in this petition.

i. Universeye Finwing Penguin

The Penguin consists of a lightweight battery operated fixed wing aircraft, a computer based ground control station (GCS), onboard cameras and associated communications equipment. The aircraft carries an onboard geographic referenced camera that allows it to perform precision photogrammetry and crop scouting at the resol utions necessary for precision agriculture. This high

- resolution data can direct prescriptions for variable seeding rates and precision application of fertilizer and agricultural chemicals.

The petitioner requests relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates. In accordance with the statutory criteria provided

in Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has previously determined that this aircraft meets the conditions of Section 333 (See exemption No. 11724

– Galaxy UAV Systems; see also exemption No.

11571

– H AZON Solutions, LLC).

ii. DJI Phantom 3 Professional

The requested exemption would permit commercial operation of the DJI Phantom 3 Professional, which weighs less than 55 lbs. and travels at significantly less than 87 knots, by Petitioner. The

DJI Phantom 3 P rofessional is entirely battery operated and will be operated by an individual(s) during daytime Visual Flight Rules (VFR) conditions and within visual line of sight (VLOS) of the pilots. Furthermore, the DJI Phantom 3 Professional will abide by all rules and regulations regarding the certain distances away from airports or heliports th e platform must remain while being operated.

The DJI Phantom 3 Professional has the following specifications:

Weight (Including Battery and Propellers)

– 1280 gram [approximately 2.82 lbs]- 4 of 15

- Diagonal Size (Including Propellers)

– 590 mm

Max Ascent Speed

– 5 m/s

Max Descent Speed

– 3 m/s

Hover Accuracy

- Vertical +/

- 0.1m

- Horizontal +/

- 1.5m

Max Speed

- 16 m/s

Max Altitude Above Sea Level

– 6000m

b. The Crew

The Crew for the operation of both UAS’s will consist of a pilot in command (PIC) and at least
one visu al observer (VO). The PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal Government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

The PIC and VO wil l receive training in the operation(s) of both UAS’s generally and will receive up

- to

- date information on the UAS’s to be operated pursuant to this grant. The PIC will have completed, at a minimum, 10 hours of UAS flight training with each specific UAS

– U niverseye Finwing Penguin or DJI Phantom 3 Professional

– prior to commercial operation of said UAS, and will be required to participate in annual training thereafter.

c. Flight Conditions

The petitioner requests exemption to fly UAS platforms in Class G airspace nationwide at or up
to 500 feet above ground level (“AGL”), unless otherwise prescribed by an ATO issued COA, and under controlled conditions over rural agricultural property. Petitioner will work with the local FSDO when planning operations. Petitioner will only operate its UA in visual meteorological conditions (“VMC”). The UA will at all times be no less than 500 feet below and no less than 2,000 feet horizontally from a cloud, and petitioner will not conduct operations unless visibility is at least 3 statute miles from the PIC. The f light crew will always make a safety assessment of the risk of every operation, and will only operate when it is determined that no hazards are present.- 5 of 15

- The 500 feet AGL limitation is in line with the Small UAS Notice of Proposed Rulemaking (NPRM). Opera tion and Certification of Small Unmanned Aircraft, 80 Fed. Reg. 9543 at 9547 (proposed Feb. 23, 2015 (to be codified at 14 C.F.R. Parts 21, 43, 45, et al.)). The FAA determined that this higher ceiling was a safe limit because:

“most manned aircraft ope rations take place above 500 feet. Specifically, most manned aircraft operations conducted over uncongested areas must be flown at an altitude above 500 feet AGL, while most manned aircraft operations conducted over congested areas

must be flown at an even higher altitude. Thus, a 500

- foot altitude ceiling for small UAS operations would create a buffer between a small unmanned aircraft and most manned aircraft flying in the NAS... [T]here is significantly less air traffic at or below 500 feet

than there is ab ove 500 feet altitude. As a result of this difference in air

- traffic density, the FAA has determined that small UAS operations would not pose a significant risk to manned aircraft operations taking place below 500 feet altitude if proper precautions are

ta ken by the small UAS operator” Id . at 9562

- 63.

Should the FAA not allow flights up to 500 feet AGL under this exemption petition, petitioner requests exemption for:

(i) flights limited to 200 feet AGL, in accordance with the “blanket” COA which now

autom atically accompanies new §333 exemption grants, under the FAA’s summary grant process for Section 333 exemptions ( see https://www.faa.gov/news/updates/?newsId=82245 ; see also https://www.faa.gov/news/updates/?newsId=82485 ); or

, in the alternative

(ii) flights limited to 400 feet AGL, in accordance with prior exemptions for the two UAS platforms for which petitioner requests exemption (For Universeye Finwing Penguin: see exemption No. 11724

– Galaxy UAV Systems; see also exemption No. 11571

– HAZON Solutions, LLC; For DJI Phantom 3: see exemption No. 13101

– Elevated Vision, LLC).

Note: Petitioner will adhere to any conditions and res trictions set forth in any grant of exemption issued by the FAA pursuant to this petition, but respectfully requests an exemption allowing flights up to 500 feet AGL.

d. Proposed Uses

The petitioner requests authority to use the above UAS platforms for the following commercial usage settings:

1. precision agriculture;

2. 2D and 3D mapping;

3. Photography;

4. Cinematography;

5. Aerial Data Collection;- 6 of 15

- 6. Filmmaking;

7. Live and taped broadcasting;

8. Visual Inspection

- primarily towers, poles, pipelines, powerlines, cables, bridges, flare stacks, chimneys, vertical structures, solar arrays, wind generators, pow er stations & sub s tations, coal ash ponds, absorbers, and buildings;

9. Real estate;
10. Golf courses; 11. Orthographic photos;

12. Special Events;

13. Construction progress; 14. Public serv ice

- Primarily:

a. search & rescue, b. law enforcement,

c. fire,
d. security,

e. disaster management & relief,

f. wildfires,

g. floods,
h. hurricanes,

i. news broadcasting, and j. tornados;

15. Banner towing (for advertising);

16. Announcements;

17. Radio Frequency directional finding

- Primarily:

a. fire & rescue, b. animal tracking,

c. Alzheimer patient tracking,

d. non

- cooperative satellite communication interception,

e. stolen vehicles,

f. high value assets,

g. hikers, and
h. skiers;

18. Radiation detection;

19. Noxious gas detection;

20. Forestry &logging;

21. W ildlife management;
22. Insurance assessments;
23. Surveys;

24. Mining;

25. Volumetric analysis;

26. Research and Development;- 7 of 15

- 27. Traffic monitoring; and

28. Sporting events.

III. Proposed Conditions of Exemption

In accordance with the exemptions already granted to other operators, petitioner proposes the following conditions apply to the exemption grant issued pursuant to this petition:

1. Operations will be limited to the Universeye Penguin and the DJI Phantom 3, when weighing less than 55 pounds including payload. Proposed operat ions of any other aircraft will require a new petition or a petition to amend the exemption granted pursuant
to this petition

.

2. Operations for the purpose of closed

- set motion picture and television filming will not be permitted.

3. The UA will not b e operated at a speed exceeding 87 knots (100 miles per hour). The petitioner will use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater
than the ma ximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA will be operated at an altitude of no more than the altitude listed in the restrictions and conditions set forth by the FAA grant. Altitude will be reported in feet
AGL.

5. The UA will be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or
U.S. driver’s license.

6. All operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always mai ntains VLOS capability. The VO and PIC will be able to communicate verbally at all times; electronic messaging or texting will not be permitted during flight operations. The PIC will be designated before the flight and will not transfer his or her designat ion for the duration of the flight. The PIC will ensure that the VO can perform the duties required of the VO.

7. The FAA exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations s tated in this grant of exemption, are hereinafter referred to as the “ operating documents. ” The operating documents will be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the condition s and- 8 of 15

- limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations listed in the FAA exemption take precedence and must be followed. Otherwise, the operator will follow the procedures as outlined in i ts operating documents. The operator may update or revise its operating documents. It will be the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator will also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, th en the operator will petition for an amendment to its grant of exemption. The petitioner will contact the FAA’s UAS Integration Office (AFS

− 80) if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone ma intenance or alterations that affect the UAS operation or flight characteristics , e.g., replacement of a flight

- critical component, will undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights w ill only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight will be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator will be responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC will conduct a pre

- flight inspection and determine the
UAS is in a condition for safe fli ght. The pre

- flight inspection will account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator will follow the UAS manufacturer’s maintenance, overhaul,

r eplacement, inspection, and life limit requirements for the aircraft and aircraft
components.

12. Each UAS operated under an exemption granted pursuant to this petition will comply with all manufacturer safety bulletins.

13. Under an exemption granted pursuant to this petition, a PIC will hold either an airline
transpo rt, commercial, private, recreational, or sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.- 9 of 15

- 14. The operator will not permit any PIC to operate unless the PIC demonstrate s the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under an exemption granted pursuant to this petition, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels,

ve hicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and
determini ng the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under an exemption granted pursuant to this petition will be conducted only under the terms of the exemption granted pursuant to this petition. However, training operations will only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations will be considered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC). Flight s under special visual flight rules (SVFR) will not be authorized.

16. The UA will not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not
denoted with an ARP, the center of the airport symbol as denoted on the current FAA

published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of

agreemen t with the airport management will be made available to the Administrator or any law enforcement official upon request.

17. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA will return to a pre

determined location within the private or controlled

- access property.

19. The PIC will abort the flight in the event of unpredic ted obstacles or emergencies.

20. The PIC will be prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at l east five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations will be conducted in accordance with an ATO

- issued COA. The petitioner will apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of a COA issued pursuant to this petition.- 10 of 15

- 22. All aircraft operated in accordance with this exemption will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents will be made available to the Administrator or any law enforcement official
upon request.

24. The UA will remain clear and give way to all manned aviation operations and
activities at all times.

25. The UAS will not be operated by the PIC fr om any moving device or vehicle.

26. All Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500
feet of the UA , flight operations will cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures grants permission for operating closer to those objects and the PIC makes a safety a ssessment of the risk of operating closer to those objects and determines that it does not present an
undue hazard.

The PIC, VO, operator trainees or essential persons will not be considered nonparticipating persons under this exemption.

27. All operat ions will be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

29. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the
NTSB Web site: www.ntsb.gov

.- 11 of 15

- IV. Privacy

There is little concern that the proposed flights will cause invasion of privac y because of the manner in which the flights will be conducted. The flights will occur over rural, private farmland that Petitioner has been contracted to fly over. At all times of operation, the platform’s onboard camera will be focused on the ground area , which Petitioner has been hired to fly over. At no point during operation will the platform’s cameras focus on nonparticipating persons. Upon completion of each scheduled flight, the platform’s data will be collected, the file will be trimmed to only contain pertinent images of the field being monitored, and the data collected will never be shared to any person or entity other than those persons employed by Petitioner and Petitioner’s client(s).

Petitioner intends to conduct flight operations in Idaho, among other places. Idaho Code section

21

- 213 requires that any operator of a UAS adhere to specific consent r equirements before capturing information about

, or photographs of

, individuals. The petitioner will at all times adhere to the requirements of I.C. 21

- 213

. Therefore this state law does not significantly affect the privacy concerns regarding the grant of an exemption pursuant to this petition.

V. Public Interest and Safety

Using UAS’ s to conduct surveillance of agriculture in lieu of manned aircraft will enhance safety

and reduce the impacts on the environment. Specifically, the small size and maneuverability of the UAS’s will create much less risk of injury upon a person than would be present if a large,

manned

- aircraft wer e to do similar surveilling. Furthermore, with both UAS’s being operated solely by battery power, the environmental impact due to emissions is essentially non

- existent.

The granting of this petition will further promote public interest in that there is a potential for economic growth, both for Petitioner and the agricultural industry as a whole. With the services provided by Pet itioner, through the use of UAS , members of the agricultural industry will be able

to attain data and statistics at a fraction of the current costs. As the agricultural industry begins to reap the benefits of obtaining the same information for less cost, it can be assumed that the industry will pass on the cost reduction to individuals in and around their area.

In sum, there are thr ee main public interests which favor the granting of this petition: (1) providing a much safer method in which to collect and compile data, which is critical to sustainable agriculture operations ; (2) reducing, if not eliminating altogether, the environmen tal impact of surveilling agricultural operations; and (3) the potential for economic growth. In sum, Petitioner’s use of UAS’s to assist the agricultural industry is a benefit not only to farmers, but to the public as a whole, and the environment.- 12 of 15

- VI. Regul ations from Which Exemption is Requested

FAR Provision Description of Provision FAA Exemption Decision 21(h) Requirements regarding
airworthiness certificates Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11111, 11110, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11189, 11191, 11192, 11193, 11195

43.7 Persons authorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or compone nt parts for return to service after maintenance, preventive maintenance, rebuilding, or
alteration No. 11208

43.11 Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and
135.419 No. 11208

45.11 Marking of products No. 11208

45.27 Location of marks on fixed

wing aircraft No. 11188

45.29 Size of Marks Nos. 11136, 11157, 11170, 11185, 11193 61.113(a) and (b) Private pilot privileges and
limitations: Pilot in command No. 11318

61.23 Medical cert ificates: Requirement and duration No. 11318

91.7(a) Civil aircraft airworthiness Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11177, 11178, 11184, 11185, 11188, 11189, 11191, 11192, 11193, 11195, 11204- 13 of 15

- 91.9(b)(2) and (c) Civil aircraft flight manual, marking, and placard requirements Nos. 11136, 11174, 11185

91.103(b)(2) Preflight action No. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11138, 11150, 11153, 11156, 11158, 11160, 11161, 11166, 11167, 11171, 11172, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195,
11204
91.105 Flight crewmembers at
stations No. 11185

91.109 Flight instruction; Simulated instrument flight and certain flight tests Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11166, 11167, 11170, 11171, 11174, 11177, 11184, 11185, 11189, 11191, 111 92, 11193, 11194, 11195, 11206,
11208 91.113(b) Right

- of

- way rules: Except water operations No. 11238

91.119(c) Minimum safe altitudes:
General Nos. 11162, 11163, 11164, 11165, 11166, 111080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193

91.121 Altimeter settings Nos. 11162, 11163, 11164, 11165, 11166, 111080, 11109, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166, 11167, 1 1170, 11171, 11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193 91.151(a) Fuel requirements for flight in
VFR conditions Nos. 11110, 11153, 11156, 11161; 111109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166,- 14 of 15

- 11167, 11170, 11171, 11172, 11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193

91.203 (a) and (b) Civil aircraft: Certifications required Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 111 70, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195
91.215 ATC transponder and altitude reporting equipment and use No. 11185, 11195

91.403 Maintenance, Preventative Maintenance, and Alterations:
Ge neral No. 11185

91.405(a) Maintenance, Preventative Maintenance, and Alterations: Maintenance required Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195,
11204 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195,
1120 4 91.409(a)(1) and (a)(2) Inspections Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158,- 15 of 15

- 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11 184, 11185, 11188, 11189, 11191, 11192, 11193, 11195, 11204 91.417(a) and (b) Maintenance records No. 12820